city of whittlesea submission to infrastructure … · web viewthe focus should be on restoring...

Submission in response to Infrastructure Victoria’s Draft 30-Year Infrastructure Strategy for Victoria

31 October 2016

Table of Contents Table of Contents.................................................................................................................................2

Introduction.........................................................................................................................................3

Further Information.............................................................................................................................3

Feedback..............................................................................................................................................4

Key considerations..............................................................................................................................4

Strategy Implementation.....................................................................................................................5

Funding Recommendations.................................................................................................................5

Strategic Framework...........................................................................................................................5

Integrated Planning ......................................................................................................................6

Objectives......................................................................................................................................8

The Common Link – ICT and Mobile Coverage..............................................................................8

Responding to Needs...........................................................................................................................11

Equitable Access for all People with Disabilities..........................................................................11

Lifelong learning..........................................................................................................................11

Community Infrastructure...........................................................................................................11

Cemeteries..................................................................................................................................12

Health Prevention........................................................................................................................12

Health Infrastructure...................................................................................................................13

Address Increasing Demand on the Justice System.....................................................................13

Social and Affordable Housing.....................................................................................................14

Water and Waste Infrastructure..................................................................................................16

Environmental sustainability.......................................................................................................17

Transport Infrastructure and Access to Employment Centres.....................................................18

City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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IntroductionThe City of Whittlesea (CoW) welcomes the opportunity to make a submission in response to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria (the Strategy).

This submission includes the CoW views on the Strategy priorities, the articulation of Needs and Objectives, and provides thematic feedback on the Strategy’s response to Needs. In some cases more specific feedback on the Strategy options is provided.

The CoW has provided feedback on previous consultations including ‘Laying the Foundations’ and ‘All Things Considered’. The CoW will not be seeking to vary the views contained in the previous submissions. This submission responds to new or augmented material and in some cases reiterates significant recommendations that were provided in previous submissions that have not been addressed in the draft Strategy. Given this is the last opportunity to provide feedback before the final Strategy is tabled in Parliament, it was considered important to re-emphasise these important considerations.

Further Information For further information regarding this submission please contact Liana Thompson, Director Partnerships and Engagement on 9217 2383 or [email protected].


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mailto:[email protected]

Feedback

Key considerations1. Generally the draft Strategy is based on a sound Strategic Framework and the vast majority of

recommendations are supported.

2. The Strategy should prioritise the significant infrastructure needs for green-field developable land in Melbourne’s growth areas and should seek to redress the historic chronic under funding of services and infrastructure in these areas. These areas account for approximately 30 years of development requiring significant additional investment in social and physical infrastructure.

3. Effort should be made to explore bi-partisan support for the Strategic Framework so that one set of guiding principles can be used in developing long term infrastructure strategies (even if specific projects may vary over time).

4. Currently the delivery of major infrastructure projects is primarily concerned with budgets and timeframes. The final Strategy should have a greater emphasis on facilitating place-making, promoting urban development and positive social outcomes.

5. The final Strategy should include a recommendation to resource and formalise partnerships between State and local governments for integrated planning and joint infrastructure.

6. The final Strategy must include the early delivery of the extension of rail services to Wollert. The current potential option of delivering a ‘high capacity’ bus system will provide a short term solution to the already established community of 45,000 people by 2021 but will not be sufficient for a growth area of over 100,000 people at full build out.

7. A less risk-averse approach to infrastructure funding and financing will need to be taken to deliver the infrastructure that Victoria needs to remain a vibrant and connected place into the future. This topic should be more central to the final Strategy.

8. The final Strategy should fully integrate climate change mitigation and adaptation throughout the document and emphasise the role that infrastructure can play in reducing emissions beyond building performance efficiencies. Given the number of recommendations requiring built or expanded infrastructure there should be greater focus on prioritising lowering emissions of construction materials and reducing emissions in the transport sector.


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Strategy Implementation The Strategy implementation and review plan indicates a desire to create a new Delivery Plan every five years, after which it could in turn review the efficacy of the Strategy and make changes where necessary. This would ensure the Strategy has the appropriate amount of weight, a clear and logical delivery program and an embedded review program to track its progress against the Strategic Framework. Under such an approach, it would be preferred to achieve bi-partisan support for the Strategic Framework so that both major parties have the opportunity to shape and review its implementation over time.

Funding Recommendations The draft Strategy includes relatively cursory reference to funding and financing options. These options generally cover the broad gamut of options and considerations in funding infrastructure. The final Strategy should place more emphasis on value capture exercises as these offer significant redevelopment opportunities. There has been a trend for Australian governments to be relatively risk averse in how they approach debt funding in relation to infrastructure projects. For the Strategy to be successful, it is clear that there will need to be major increases in spending over time. This necessitates a different philosophy to these issues. For example, the economic benefits associated with constructing projects, coupled with the competiveness of Victoria as an investment destination may ultimately outweigh the risks associated with debt funding.

Growth area municipalities face significant fiscal challenges in funding both infrastructure in growth areas and growing and maintaining infrastructure for established suburbs. The CoW welcomed the introduction of the State Government Growing Suburbs Fund which is a step towards addressing the significant infrastructure lag in growth areas. It is recommended the final Strategy continue this fund and increase it from a $50 million pool of funding per annum to $100 million per annum.

Generally, funding recommendations should have a greater emphasis on the equitable distribution of costs across population groups. In particular, funding recommendations that relate to user charges should not add further burden to disadvantaged or vulnerable people.

Strategic Framework The CoW supports the need to direct growth to areas where there is already considerable infrastructure and in turn, upgrade that infrastructure to support continued growth. This is consistent with the intent of the previous Plan Melbourne (and most contemporary planning strategies). However, it is critical to note that there is approximately 30 years’ supply of green-field developable land in areas such as the City of Whittlesea, which is within the same timeframe as this Strategy. This supply was driven by the State Government’s decision to extend the Urban Growth Boundary in 2010, a continuation of a long term trend towards urban sprawl.

The relative ease of developing green-field land as opposed to the favoured transition towards urban intensification will take considerable time to eventuate. As a result, the Strategy must seek to redress the historic underfunding of these areas if Government wants to pursue a truly equitable, integrated and vibrant Melbourne. To do this, funding sources such as the Growth Area City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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Infrastructure Contribution will become increasingly important elements of any pipeline of infrastructure funding. As per Recommendation 11.1.1 this process must ensure that local needs are considered by State government working with local government.

Integrated Planning From a State and regional perspective, it is crucial to note the link between key planning documents and revenue streams coming from the development sector, and the role the sector can and should play in directing growth, and correspondingly infrastructure investment.

The principal document from a planning perspective for the State will be Plan Melbourne, which is yet to be finalised. Importantly the Strategy references the need to integrate carefully with this and other planning documents, however it is hard to provide an integrated critique of this Strategy in the absence of a clear position from the State Government on its principal planning strategy.

The Strategy suggests that integrating land use and infrastructure planning is best achieved by transitioning towards a system where infrastructure plans guide land use planning. While the Guiding Principle of aligned and integrated planning is a sound idea, it would be more appropriate to approach this as a cycle process as opposed to a linear interaction. This is indicatively outlined below in Figure 1. Furthermore, this strategy is an important opportunity to address the historic disconnect1 between social planning, land use and infrastructure planning in Victoria. Addressing this gap is necessary to maximise community outcomes into the future. It is recommended that the final Strategy clearly define the relationship between social and physical infrastructure planning. The Growth Area Social Planning Tool2 provides resources and evidence to support coordinated social planning processes.

1 Victorian Auditor-General, Developing Transport Infrastructure and Services for Population Growth Areas, Parliamentary Paper No 249, Session 2010-13, State Government of Victoria, 2013; Outer Suburban/Interface Services and Development Committee, Inquiry into Growing the Suburbs: Infrastructure and Business Development in Outer Suburban Melbourne, Parliamentary Paper 236 Session 2010-13, State Government of Victoria, June 2013. ; Outer Suburban/Interface Services and Development Committee, Inquiry into Liveability Options in Outer Suburban Melbourne, Parliamentary Paper No 149 Session 2010-12, State Government of Victoria, December 2012

2 http://www.socialplanningtool.net.au/default.aspCity of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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Figure 1: Example of an integrated social, land use and infrastructure planning model

For social, land use and infrastructure planning to become truly integrated, the approach to delivery is as important as the strategy development. It is the CoW’s observation that once a strategic plan is agreed to and funded, the metrics applied to the delivery process are largely quantitative (time and budget) and do not have the required emphasis on the quality of the outcome, in particular, the critical role that strategic infrastructure projects have in place making, positive social outcomes and in driving future investment. Key Performance Indicators for large projects should be designed to achieve Triple Bottom Line outcomes (economic, social and environmental) and promote urban development.

As an example, the current project to extend rail to Mernda Town Centre has a clear policy justification and infrastructure spend - the project connects rail services to a future major town centre at the heart of one of Australia’s largest growth areas. However, the project could be strengthened if there was scope to address more qualitative measures that would see the project meaningfully integrated into the fabric of the town centre. The risk of purely focussing on time and budget as the primary drivers will likely see the project deliver a transport interchange that is planned and delivered in isolation to planning scheme material that has previously been subject to approval by the Minister for Planning.

It is understandable that delivery agencies are mindful of and accountable against time and budget pressures. However, in a more integrated and strategically focussed environment, there would be a greater emphasis to deliver the best possible social and physical outcomes for major structural investments and working with local government and other state government departments to deliver infrastructure in a holistic way. Project delivery should be informed by communities’ social infrastructure needs and in consideration of broader integration with existing and planned City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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Integrated social, land

use & infrastructure

planning

Direct growth to areas with

infrastructure capacity.

Build on the capability of designated

locations for growth by improving

infrastucture.

Targeted infrastructure

improvements to link areas of strategic

importance.

Address social needs through gap

infrastructure funding

infrastructure and services. Collaborating early with local government provides the opportunity to incorporate a place-making approach on large scale state government projects, in context with timeframes and budgets. Building on this theme, Recommendation 11.1.2 Government service/infrastructure planning describes the need for ‘area-based, whole-of-government, integrated service and infrastructure planning and investment prioritisation processes.’ For this recommendation to be effective it should include mechanisms to collaborate with local government early rather than focusing on integrating state government first and engaging with local government later. The new Metropolitan Partnerships model could also provide further opportunities to facilitate integrated planning with local government.

Objectives Objective 3 Reduce Disadvantage

It is recommended that this objective be rephrased to ‘Provide equitable access and reduce disadvantage’. This distinction is important as disadvantage can only be addressed where the overall aim is to pursue equitable infrastructure planning. It is necessary to strengthen the language used in this objective to affect real change.

Objective 9 Advance climate change mitigation and adaptation

The CoW agrees with the need to take action on climate change. However this could be strengthened by better integrating Objective 9 through the document in a concerted way. While facilitating a reduction in energy consumption and enabling an orderly transition away from brown coal are important steps, more needs to be offered in this Strategy about the role infrastructure can play in reducing emissions beyond building performance efficiencies. Given the number of recommendations requiring construction works or transport infrastructure there could be greater effort to prioritise lowering emissions of construction materials or mention of the benefits of reducing emissions in the transport sector. Similarly, the resilience of key infrastructure (Need 19) is more focussed on current disaster/emergency management than climate change adaption. There is little mention of planning for climate change projected futures in any other recommendations. Given that advancing climate change mitigation and adaptation is a key objective of this Strategy stronger reinforcement of this theme in the document is recommended.

Further, the objectives could include the significant opportunity to investigate industrial relations solutions to flexible working arrangements which would reduce stress on transport networks during peak times. This supports a less reactionary and more strategic approach to prioritising infrastructure spending across the state.

The Common Link – ICT and Mobile Coverage The CoW is pleased that the essential nature of high speed broadband and the need for complementary mobile connectivity is highlighted in the draft Strategy. These communications technologies will underpin strong regions and future economic growth. However, care must also be taken to ensure that ICT solutions do not adversely affect those in the population who are not


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technologically literate or connected. The introduction of ICT in the health sector for example, should be accompanied by giving attention to increasing the health literacy of the population.

Broadband

For residents in growth areas that will not be connected to the NBN rollout, poor fixed line internet infrastructure is a key issue. The Telecommunication Ombudsman produces an Annual Report each year that highlights the areas with the highest number of complaints regarding telecommunications coverage. The latest report (2014-15) highlights significant growth in the number of complaints relating to slow internet speeds in newly developed areas of Melbourne.3

Most consumers from these areas reported slow data speed as an ongoing issue (the reported problem occurred “for a year now”, “in the last few months” or “since I moved to the area”), which suggests there may be capacity problems in these areas.

Poor connections also slow economic development and impact the delivery of services in these areas. For example Council run community centres have ongoing problems with internet connectivity preventing staff based in the centres from effectively doing their job and limiting the services available to residents.

Often these areas have no broadband because they are connected by Telstra copper, and the number of ports at the exchange are fully utilised. Under the Telecommunications Act, Telstra is only required to provide a telephony service. Telstra is not funding additional ports in the exchange because they will eventually be replaced by NBN connections. This means that residents have to use mobile devices for data which are slow and expensive. These areas are often adjacent to newer estates (or even next door) with fibre access to the premises and ultra-fast broadband.

Council’s view is that urgent attention is required to ensure that pockets of broadband disadvantage are not propagated due to the limited rollout timetable in growth areas where subdivision stage 5 approval was given before 1 January 2011.

Mobile Coverage

The Federal Government policy approach to mobile coverage is that in urban regions the marketplace will deliver effective competition and deliver outcomes acceptable to local residents. Rural and Regional areas will be subsidised using Federal Government funding programs like the Mobile Blackspots program to provide acceptable solutions to rural and regional residents, visitors and businesses. The feedback from residents is that market forces are not providing adequate outcomes for outer metropolitan suburbs.

The Telecommunication Ombudsman (2012) found that four of the top five suburbs reporting the highest number of complaints were growth areas. All of the top ten suburbs reporting complaints are metropolitan areas where market forces should be providing adequate services.4

3 2015 TIO Annual Report http://www.tio.com.au/publications/annual-reports

4 2012 TIO Annual Report http://www.tio.com.au/publications/annual-reports City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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http://www.tio.com.au/publications/annual-reports

http://www.tio.com.au/publications/annual-reports

Growth areas in the CoW reported high numbers of complaints, including Doreen with the fourth highest number of complaints in Australia and the second highest in Victoria, and Epping which had the fifth highest rate in Victoria. Most of these complaints were related to poor mobile coverage.

The CoW’s view is that market forces are not resolving poor mobile coverage in urban areas and specifically growth areas which is exacerbated by poor fixed line broadband infrastructure. The policy approach needs to be revisited to ensure that mobile coverage in growth areas keeps pace with population growth.


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Responding to Needs Equitable Access for all People with Disabilities The Cow strongly reiterates that Need 6. Improve accessibility for people with mobility challenges be rephrased to Improve accessibility for people with disabilities to account for people with disabilities that are not related to mobility. This need should emphasize the importance of ensuring universal design principles that accommodate all ages and abilities.

There is an opportunity to include a recommendation that encourages private transport providers to ensure their infrastructure accommodates all ages and abilities, as highlighted for public services in Recommendation 6.1.3 Public transport accessibility.

Lifelong learning Need 9 Provide access to high-quality education infrastructure to support lifelong learning primarily focuses on schools as sites for lifelong learning and, apart from libraries, makes little reference in recognising opportunities to deliver services through other facilities such as neighbourhood houses, community centres and universities. It is recommended that this section have a stronger focus on providing a diversity of learning facilities that accommodate all ages and stages.

Libraries

The provision of libraries in growth areas should be addressed in the Strategy. Libraries provide a lifelong learning hub and are an essential community building block. The early provision of libraries in growing communities is therefore essential. However, the capital cost to deliver libraries is cost prohibitive for councils. The CoW experience is that Libraries cost approximately $12 million to construct however the state government Living Libraries Fund allocates a maximum of $750,000 per facility. This provides a significant shortfall in capital funding and a budget challenge for local government. This is a pertinent issue for the CoW with five new libraries required in newly developed or developing areas within the next 5-15 years including Mernda, Epping North, Wollert, Donnybrook-Woodstock and Epping Central. More capital funding support from state government is required.

Alternative Education for Young People

Need 9 should consider alternative education for disengaged young people (for example the Pavilion School in Preston and South Morang), as well as providing greater capacity for schools to deliver VET and VCAL.

Community Infrastructure A Partnership Approach

An integrated approach to delivery of community infrastructure requires investment in the establishment of partnerships. To support partnerships between state agencies and local government or local service providers, a resourced approach to brokerage is required. The final Strategy should support the investigation and delivery of a brokerage model for government to implement the co-ordinated delivery of infrastructure.


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1.4.2 and 5.2.2 Community space shared use agreements

The CoW strongly endorses this recommendation and suggests the timeframe be brought forward to 0-5 years. Shared use agreements are a significant impediment to the co-location of facilities on State Government sites, particularly schools. There are numerous co-location opportunities in growth areas that require shared use agreements to be in put in place within 5 years, for example Mernda Town Centre development.

5.3.1 Schools as community facilities

The CoW recommends the timeframe for Recommendation 5.3.1 Schools as community facilities be brought forward to 0-5 years. There are opportunities to deliver new schools as community facilities now. Delaying action to 5 years and beyond will mean the integration of schools and community facilities will only be possible through costly retro-fitting. At least three new primary schools (not including recently funded schools) are required in the City of Whittlesea in the next 5 years. These schools are needed in new developments where there are extensive opportunities to integrate community facilities and services, which would significantly strengthen community outcomes.

For this recommendation to be effective there needs to be a formalised partnership between the Department of Education and Training, local government and other stakeholders including appropriately resourced partnership brokerage and governance arrangements. Collaborative planning and delivery of school and community infrastructure would help deliver flexible learning spaces that are well connected and responsive to local needs.

This recommendation could also be broadened to include opportunities to co-locate other community services such as early years’ services, early intervention, family support, counselling or Maternal and Child Health. Depending on the service being co-located, complex legal leasing arrangements may need to be resolved.

1.4.3 and 5.4.1 Relocatable community infrastructure

This recommendation should include consideration of universal design and good facility design for temporary infrastructure. Provision of temporary infrastructure should be appropriate and should not result in reduced standards that negatively impact on communities.

Cemeteries

It is recommended that the final Strategy also address the provision of cemeteries which appear to have been overlooked in the consultation papers to date. With an increasing older population it is important that timely and appropriate land planning for this infrastructure be acknowledged.

Health Prevention Need 4. Enable physical activity and participation should address the need to create public open space in new growth areas beyond the use of schools as community facilities. The final Strategy should have a focus on preserving critical land / green spaces for people to use and experience. In established areas this includes preserving existing green spaces, and as population density increases there needs to be mechanisms to release more land for green spaces. Open/green spaces also provide opportunities for communities to gather.


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Health Infrastructure Need 3. Respond to increasing pressures on health infrastructure, particularly due to ageing

3.2.3 Integrated community health hubs

This recommendation could be brought forward to 0-5 years as there are opportunities in Whittlesea’s growth areas to begin designing these facilities now for example Mernda Town Centre development, Plenty Valley Community Health South Morang Master Plan, and Melbourne Polytechnic Re-development in Epping. The Health Service Planning for the Northern Region currently being undertaken by Department of Health and Human Services is also likely to identify opportunities for community health within the next 5 years.

Integrated community health hub should be delivered in conjunction with improved urban design to enable and encourage better health and lifestyle outcomes through regular activity and socialisation as referred to in Need 4.

3.3.2 Mental health/AOD facilities.

This recommendation focuses on secondary and tertiary provision. There are opportunities to provide infrastructure to support preventative mental health (particularly for young people) such as incorporating spaces into schools. There is an urgent need for affordable and flexible mental health services that are available for all ages and stages including maternity, children and young people. Schools provide a universal platform for health and human services prevention programs and services.

3.4.1 Aged care facility approvals.

Aged care facility approvals are also required in the growth areas where the total numbers of older persons is significantly increasing (double current population in Whittlesea by 2036). Facility provision needs to address the lack of spaces currently provided for dementia care which is expected to increase significantly in future years.

Health Information and Health Care ICT Systems

Health information needs to be considered in the widest context and in consideration of the relationship between different service sectors e.g. public and private health systems, acute and community based systems, adult and child focused services. Professionals such as family support and MCH generate health information which present opportunities to link these information systems into broader health care ICT systems.

Address Increasing Demand on the Justice SystemAdditional recommendation – Co-located Justice Services at Civic Facilities

The CoW strongly supports the focus on integrating justice and human services however there is limited focus on exploring new ways of delivering justice services in the Strategy. The recommendations presented continue the current approach - building new facilities as large justice City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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precincts or refurbishing facilities in the CBD. However, there are opportunities to co-locate justice services at existing or proposed civic facilities. For example: VCAT hearings from council chambers. The CoW is currently working with Courts Victoria to explore opportunities to deliver justice services via the Civic Precinct in South Morang. This model has also been piloted at Broadmeadows and Echuca.

This model of delivery enables some justice services to be available in growth areas within the next 0-5 years and beyond through existing facilities, whilst the planning and delivery of larger facilities can continue. This recommendation would not replace the need for Recommendation 8.1.3 Courts in high growth areas but would complement this approach and provide more timely access to some justice services.

Social and Affordable HousingThe CoW fully supports the focus on urgently addressing social and affordable housing for the most vulnerable Victorians which is identified as a significant area for State government investment in the City of Whittlesea5.

Sectors and Stakeholders

There is a clear need to link affordable housing policies and provision with broader social and economic development. Infrastructure Victoria has nominated the ‘health sector, health and human services’ as the primary sector related to this Need, however it should be noted that stakeholders across many other sectors will be responsible for delivering better supply of affordable housing for vulnerable people. Housing affordability is a significant, urgent and complex issue that will require a variety of responses across policy and planning reform and, most importantly, a clear policy position and a coordinated response led by the State Government. It is also important that responsibility for the provision of social and affordable housing is not shifted from State Government to the private market/sector, community housing sector or private financiers.

It is recommended the ‘Things we considered’ section (p. 94) also highlight that secure, affordable and appropriate housing is critical for ensuring the health and wellbeing of individuals and families. Appropriate and affordable housing enables people to participate in community life. There should also be recognition of the need for a diversity of affordable housing for young people, ageing in place and women (particularly older women).

Diversity of Housing Typologies

Under Recommendation 7.3.2 Affordable housing planning mechanisms it is important to focus on achieving a diversity of housing typologies in appropriate locations. The CoW’s experience is that while densities are increasing it is generally through smaller lot sizes with the same dwelling types, which do not provide an appropriate level of diversity.

Good Design and Universal Design

5 City of Whittlesea Social and Affordable Housing Strategy City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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https://www.whittlesea.vic.gov.au/your-council/plans-strategies-and-policies/~/media/Files/Your%20Council/Plans%20and%20strategies/Social%20and%20Affordable%20Housing%20-%20Policy%20and%20Strategy%202012-2016.pdf

These recommendations should also consider good quality design outcomes for social and affordable housing as vital in enabling diversity of house uses for example, design principles articulated in the City of Adelaide Design Manual6. Currently, ResCode does not encourage good design for purpose builds to the housing sector, nor does it encourage good design for the social and affordable housing sector. These are both significant issues as affordable housing should not equate to poor design quality outcomes.

The greater provision of universally accessible dwellings will also encourage ageing in place and multi-generational living which can offer greater flexibility to individuals and families in their housing choices. Stronger direction from State Government is required to support greater provision of universal design and adaptable housing. It is important that these provisions and criteria do not compromise amenity for surrounding residents and neighbours.

Air rights

The CoW suggests considering a mechanism that encourage and facilitates ‘air rights’ and ‘air space’ developments for the provision of social and affordable housing. For example above car-parks and within transport precincts such as above train stations. This option may provide efficiency of the use of government owned land.

Effective Planning and Clear Definitions

For Recommendations 7.3.1, 7.3.2 and 7.4.1 to be successfully implemented a definition of ‘affordable housing’ in the Victorian State Planning Policy Framework (SPPF) is imperative. Use of the term ‘housing affordability’ has multiple meanings. For example, in the City of Whittlesea, much ‘affordable housing’ is evidently unaffordable due to high liveability costs. Any supported policy direction should have a clear vision and definition of social and affordable housing. A ffordable housing considerations should include the concept of ‘affordable living’ which takes into account:

Transport costs associated with accessing employment areas, services and facilities

Household expenditure on utilities

The costs of adaptable housing as household need changes, such as suitability as people age or people with a disability.

Any policy or plan should also clearly define the spectrum of social and affordable housing which includes social housing, affordable rental stock, and affordable ownership prices for first-home buyers. Figure 2 below is one example of a ‘Housing continuum’.

Figure 2. Housing continuum

6 http://www.adelaidedesignmanual.com.au/City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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http://www.adelaidedesignmanual.com.au/

Water and Waste InfrastructureNeed 14 - Manage threats to water security, particularly in regional and rural areas

The draft Strategy correctly identifies the potential for stormwater harvesting (option SRH) to help augment potable water supplies and should be applauded for the scope and level of consultation presented in the document. Stormwater harvesting is considered a preferred model compared to desalination, third-pipe schemes, and wastewater to potable water treatments.

The Strategy should be balanced with equal support or acknowledgement of the potential for rainwater (eg. roof water and stormwater) to augment potable water supplies. In a future accentuated by droughts, investment in household products aimed at collecting, treating and re-using rainwater, grey water and other household wastewater will have the effect of creating an augmented “virtual supply” of potable water. Education, statutory requirements, financial incentives, innovation and water restrictions will further shape this behaviour change. The recent Millennium drought demonstrated that a 40 per cent reduction in potable water demand could be achieved using some of these initiatives.

The Strategy should also highlight the need for a long term investment in large scale stormwater harvesting operations to support agriculture in urban and peri-urban environments, and not be limited solely to the use of recycled water. In Melbourne, stormwater runoff volumes are similar to the annual potable water demand7.

Capturing and storing a significant component of this stormwater will require a coordinated effort reflective of the 30-year time period presented in the strategy. Greenfield developments in growth municipalities and the co-location of large storage options (e.g. Yan Yean reservoir) could significantly lower the costs of these infrastructure projects. There is a growing body of research that suggests that the co-location of agriculture within urban developments will be important in supporting a low carbon economy8.

Need 15 - Manage pressures on landfill and waste recovery facilities

With regards to waste, the draft Strategy should articulate a clear nexus to current State and regional waste strategies which set out the direction of waste infrastructure in the State. Furthermore, it should reference linkages to the Statewide Waste and Resource Recovery Infrastructure Plan and Metropolitan and Regional implementation plans that have recently been developed to guide future planning for State waste and resource recovery infrastructure.

In particular, Recommendations 15.1.1 Recycled materials in construction and 15.1.3 Waste pricing are speculative and require a clear direction for appropriate infrastructure to support such actions. In contrast, Recommendation 15.1.2 Organic waste appropriately references the ‘Victorian Organics Resource Recovery Strategy’ for applicable actions. From a local government perspective Recommendations 15.2.1 and 15.2.2 addressing landfill buffers and waste management sites are supported.

7 University of Melbourne (2016), Stormwater harvesting and capacity for new dams8 Lascaris, et. al., 2016. Creating Stormwater Management Plans ready for a Low Carbon FutureCity of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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Environmental sustainability Need 16 - Help preserve natural environments and minimise biodiversity loss

In general the CoW is supportive of improving the asset management of parks and providing a focus on biodiversity values outside the bounds of protected areas. Most of the recommendations are supported, and moving the Green Infrastructure (UFF) into Need 16, better reflects its role in promoting urban biodiversity. However, there are some concerns related to specific recommendations within this need.

The CoW reiterates that pursuing Recommendation 16.3.2 Habitat Corridors should not come at the expense of the protection of our existing native vegetation/fauna habitats. This recommendation requires clear objectives of what it aims to achieve. Habitat corridor may benefit certain species, but many others have low dispersal ability due to mobility and/or habitat specialisation. The focus should be on restoring ecosystem structure, function and process, rather than simply providing movement corridors. Restoration of systems is integral to building the resilience and therefore the adaptive capacity of our biodiversity.

The CoW also cautiously supports the clarified scope of Recommendation 16.2.2 Parks Partnership. With careful planning this recommendation could increase outcomes within our parks for acute issues, however it should be seen as a support system for current management, not as a replacement. The privatisation of park management presents a significant risk to the overriding direction of our State legislation for the preservation of our natural environment and indigenous flora and fauna (National Park Act 1975; Part I; Section 4). The CoW was and remains opposed to the previous scope of NPP2. While we welcome the move to change this in the current Options Paper, we would require a more comprehensive plan before offering any support.

Need 18 - Transition to a lower carbon energy supply and use

The CoW is concerned by the lack of basis for Recommendation 18.1.1 Energy Pricing (EDM2). A mandated cost-reflective pricing system is likely to have inequitable impacts on society. Charging more at peak times will force vulnerable households to bear the weight of shifting behaviour as they will be the least capable of affording the additional costs. This will have flow on impacts for people’s health and the broader economy. There is also no evidence provided as to the reduction in total energy demand, with the previous Options Paper stating that it would have “limited impact on transitioning to a low carbon future”. Given the lack of evidence and the potential inequity it is suggested that this recommendation not be included in the final Strategy.

Recommendations 18.1.2 and 18.1.3 are broadly supported however it would be preferable for the energy efficiency of existing public buildings program to be actively extended to commercial and industrial sectors. There is a well-documented lag in energy performance improvement efforts in our existing building stock, and further incentives and assistance is needed beyond leadership.

Recommendation 18.2.3 Small-scale solar, should also include a program that would assist low-income or otherwise vulnerable people to better afford solar power for their homes. Whilst it is not the specific aim of this option, and Infrastructure Victoria’s reluctance to subsidise solar more


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broadly is noted (LSE), this would fill a gap in the uptake of solar PV across the community, as well as provide financial relief and energy security to this part of the community.

Transport Infrastructure and Access to Employment CentresWallan and Wollert rail connections

The CoW strongly supports the inclusion of Wollert transport links in the final Strategy. An immediate study into providing heavy rail to Wollert is welcomed as the urban development in Epping North has been proceeding for over a decade without connectivity to Principle Public Transport Network (PPTN) creating significant disadvantage for residents and commuters, particularly those without access to motor vehicles. The current potential option of delivering a ‘high capacity’ bus system will provide a good short term option. However, this will not sufficiently cater for this area as the population is forecast at over 100,000 people at full build out. The final Strategy must include the extension of rail services to Wollert and this should be delivered in the shortest timeframe possible.

Without the rollout of mass transit to Wollert, sustainability and social issues will be compounded and the ability to create travel behaviour that delivers positive environmental outcomes and connected, liveable communities will not be realised.

Wallan electrification and connection to the metropolitan rail network must also be delivered to integrate the greenfield developments as a result of the resetting of the Urban Growth Boundary in 2010. It is noted that this project is dependent on a flyover connecting to the Upfield line.

Both of these public transport projects are examples where leadership from State Government is needed. The timely delivery of transport infrastructure is critical to integrate land use planning and infrastructure planning and deliver place-making at transport nodes. Transport infrastructure should not be delivered without regard to liveability outcomes and cannot be provided after land uses have become established with ingrained transport behaviours.

Roll-out of Strategic Cycling Corridors

The CoW supports the clear case for the State government accelerating ‘the rollout of Strategic Cycling Corridors and identified network improvements beyond priorities funded through the TAC’. The focus on delivery, rather than starting another high-level planning exercise, is commended as both State and local government have conducted multiple planning exercises in this field over many years. Most of the missing links, possible new links and dearth of facilities have already been identified in numerous local, regional and state-wide assessments but have lacked funding.

Access to Employment Centres

Mass transit linking both emerging and current outer suburbs to National Employment Centres (NEC) as identified (Page. 135) is essential to the success of this Strategy and is likely to provide significant productivity gains. The links that need to be created along key transport corridors should not only be focused on connection to the CBD but provide connectivity to outer suburbs. The recommendations under section 11.3 linking the Melbourne Airport to the CBD will not assist with accessibility for the nearby workforce residing in the outer north. Approximately 20,000 residents from the City of


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Whittlesea travel east-west for employment in Hume municipality.9 An investigation into the provision of these links is required.

The extension of light rail services, such as Tram Route 86, to the La Trobe National Employment Cluster should be investigated to provide accessibility to jobs for outer northern suburban residents, connections to higher education facilities (LaTrobe and RMIT Universities) and intensity of development along this transport corridor. The extension of Tram Route 86 also aligns with Recommendation 11.1.1 Development in/around employment centres. The CoW support the principal of increasing densities around key activity centres to make better use of existing infrastructure.

The CoW also supports the inclusion of the North East Link (11.4.6, 13.5.1) in the final Strategy as an important project for improving connectivity to other Melbourne regions and employment hubs in the CoW.

Innovative transport services Recommendation 1.3.1 Innovative transport services could include and recommend support for community transport models that enable those who are unable to access public transport to get around and to fill the gaps not provided by public transport options.

Recommendation 6.2.1 On-demand transport services should also include a focus on addressing transport disadvantage in growth areas.

Intermodal Freight terminals

The draft Strategy includes no direct reference to freight terminals. The final Strategy should place more emphasis on the advice Infrastructure Victoria is preparing as part of ‘Advice on Victoria’s Future Ports Capacity’ which in turn will inform the infrastructure required for the chosen location option. These options should be prepared as addendums to this draft Strategy. The CoW believes the proposed Intermodal Freight terminal at Beveridge will provide a significant economic boost to the fast growing northern region.

Arterial roads

Recommendation 1.3.5 Outer metropolitan arterial roads, urgency is required to upgrade arterials in outer metropolitan areas given high population growth and lag in road infrastructure keeping pace with development restricting accessibility to employment areas such as Epping MTC (11.1.1). The proposed time frame should be revised and prioritised in the coming 5 years.

Outer Metropolitan Ring Road (OMR) and E6

The CoW supports the construction of OMR (Recommendation 11.4.7). However the inclusion of the E6 (Hume Freeway to M80) in the OMR as a freeway is not supported by the CoW’s research shows the E6 should be constructed as an arterial road.

Outer Suburban Public Transport

9 Source: Census 2011 data extrapolated to reflect current forecast population figures. Population figures sources from http://forecast.id.com.au/whittlesea .City of Whittlesea Submission to Infrastructure Victoria’s Draft 30 Year Infrastructure Strategy for Victoria October 2016

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http://forecast.id.com.au/whittlesea

As most public transport coverage in the outer suburbs is provided by bus, the CoW supports additional bus services in growth areas including proposed timing (recommendation 11.4.2 and 11.4.3).


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